International

  • November 30, 2020

    Telecom Seeks $109.3M Tax Refund On Foreign Income

    The federal government owes $109.3 million in overpaid taxes and penalties to a Colorado telecommunications corporation after the government's erroneous, retroactive application of a provision in the 2017 federal tax overhaul, the company told a federal court.

  • November 30, 2020

    OECD Issues Report On Tax Preferences For Philanthropy

    The Organization for Economic Cooperation and Development released a new report on tax policies to promote philanthropy, outlining how government can ensure that preferences to encourage charitable giving do not produce adverse effects in contradiction to the policy's goals.

  • November 30, 2020

    OECD Gives Jurisdictions Diagnostic Tool To Fight Tax Crime

    Tax jurisdictions have a new tool that enables them to assess how effective they are in fighting tax crime, the Organization for Economic Cooperation and Development said Monday.

  • November 30, 2020

    Capital Gains Tax Is Red Line For Head Party In Belgian Gov't

    The head of the party leading the new Belgian government said his party could not accept a proposal to create a national capital gains tax, calling it a deal breaker in the negotiations to form a coalition government.

  • November 30, 2020

    Tax Group Of The Year: Baker McKenzie

    Baker McKenzie led Facebook Inc.'s legal defense in its $9 billion dispute with the Internal Revenue Service this year in one of the most closely watched international tax cases in the country, helping it land a spot among Law360's Tax Practice Groups of the Year.

  • November 30, 2020

    Metals Dealer, Staffer Can't Ditch £17M VAT Scam Convictions

    An English appeals court refused Monday to overturn convictions against two men for cheating Britain's tax authority out of more than £17 million ($22.7 million), finding a covertly recorded conversation of the conspirators speaking about the crime could be included as evidence.

  • November 30, 2020

    EU Commission Insists Plastics Levy Is Not A Tax

    A proposed European Union charge on the relative quantity of nonrecycled plastic packaging waste generated in each country is not a tax, despite being mandatory and designed to feed the bloc's budget directly, according to the European Commission.

  • November 30, 2020

    Greens Want Portugal To Bring EU Tax Transparency To A Vote

    Members of the Green Party in the European Parliament have urged Portugal to bring public country-by-country reporting to a vote in the European Union's council of member states when that country begins chairing these meetings next year. 

  • November 30, 2020

    German Minister 'Confident' Of Global Tax Deal By Summer

    Germany's finance minister has said he is confident that nearly 140 jurisdictions negotiating a global tax deal can reach an agreement by the middle of next year and finish in line with a new deadline agreed to in October.

  • November 25, 2020

    Law360 Names Practice Groups Of The Year

    Law360 congratulates the winners of its 2020 Practice Groups of the Year awards, which honor the law firms behind the litigation wins and major deals that resonated throughout the legal industry in the past year.

  • November 25, 2020

    The Firms That Dominated In 2020

    The eight law firms topping Law360's Firms of the Year managed to win 54 Practice Group of the Year awards among them, for guiding landmark deals, scoring victories in high-profile disputes and helping companies navigate uncharted legal seas made rough by the coronavirus pandemic.

  • November 26, 2020

    OECD To Deliver Cryptoasset Reporting Standard In 2021

    The Organization for Economic Cooperation and Development will probably complete an information standard on crypto-assets next year, the top tax official for the 37-nation standards setter told Law360 Thursday.

  • November 25, 2020

    Dutch Finance Minister Seeks To Ease FATCA Banking Issues

    The Netherlands' finance minister is looking into whether banks can maintain accounts for individuals with U.S. citizenship if they've urged their customers to comply with the U.S. Foreign Account Tax Compliance Act, a spokeswoman for the Finance Ministry said Wednesday.

  • November 25, 2020

    Canada Court Says Woman Owes Tax On Annuity Plan Income

    A Canadian woman owes taxes on CA$10,831 ($8,329) of annuity plan income after the Tax Court of Canada found she didn't prove that it was a disability insurance plan for which she paid all of the premiums. 

  • November 25, 2020

    Danish Gov't Fires Back At Bid To Toss $2.1B Tax Fraud Suit

    Denmark's government urged a Manhattan federal judge not to toss its enhanced $2.1 billion tax refund fraud suit, arguing the claims are timely and that counterclaims should be rejected on the same grounds the court denied an initial dismissal bid.

  • November 25, 2020

    Biden Faces Short Timetable On OECD Digital Tax Talks

    As Joe Biden's team races to staff his administration, ensuring that the U.S. Treasury Department has key decision-makers in place to negotiate an agreement with other OECD countries on international taxes could be a significant challenge.

  • November 25, 2020

    Manhattan DA Takes Manafort Case To NY's Highest Court

    Manhattan District Attorney Cyrus Vance is moving forward with appealing the dismissal of state fraud charges against former Trump campaign chairman Paul Manafort to New York's highest court, after two lower courts agreed the indictment should be dismissed on double jeopardy grounds.

  • November 25, 2020

    Companies Receive Notice To Pay French Digital Tax

    Companies subject to France's digital services tax have received notice to pay the tax, the government confirmed in a statement Wednesday, a move that could sour relations between France and the United States as the new U.S. president takes office. 

  • November 24, 2020

    Canada Court Says Hands Tied In Bid For Property Tax Rebate

    An entity formed by an Ontario firefighter who later died can't obtain a rental property rebate because of a late-filed application, the Tax Court of Canada ruled, saying it lacked authority in the matter but found relief was warranted.

  • November 24, 2020

    Canadian Tax Court Says Businessman Doesn't Owe $35K

    A businessman who sold a property in Montreal is not liable for the transaction's CA$45,750 ($35,207) goods and services tax owed by the buyer, the Tax Court of Canada ruled.  

  • November 24, 2020

    Former Treasury Official Rejoins KPMG's DC Int'l Tax Group

    A former U.S. Treasury Department official who oversaw the mammoth task of writing guidance for the 2017 tax overhaul's international measures has rejoined KPMG LLP in the firm's Washington, D.C., office, where he will work on the regulations' application.

  • November 24, 2020

    UK Climate Group Tells Activists To Withhold Tax Payments

    An environmental group has suggested that its activists withhold the payment of tax in protest over the British government's handling of climate change. 

  • November 24, 2020

    OECD To Hear Public Comments On Tax Project In January

    The Organization for Economic Cooperation and Development will hold online public consultations on the most recent drafts of its proposals to overhaul the global tax system in mid-January, an OECD official said Tuesday.

  • November 24, 2020

    EU Seeks Feedback On Planned Cryptoasset Disclosure Rules

    The European Commission is seeking feedback from industry stakeholders on rules it plans to unveil in the second half of next year that it hopes will make it harder to use cryptoassets to evade taxes.  

  • November 24, 2020

    EU Insurers Protest At New VAT For Financial Services

    European insurers hit back at the European Commission on Tuesday over proposed changes to the value-added tax regime in the bloc, saying the system is outdated and threatens the EU's capital markets union.

Featured Stories

  • Biden Faces Short Timetable On OECD Digital Tax Talks

    Alex M. Parker

    As Joe Biden's team races to staff his administration, ensuring that the U.S. Treasury Department has key decision-makers in place to negotiate an agreement with other OECD countries on international taxes could be a significant challenge.

  • 9 Things Tax Pros Are Grateful For This Thanksgiving

    Amy Lee Rosen

    From the extension of federal and state tax deadlines due to the novel coronavirus pandemic to the partial exemption for global intangible low-taxed income, tax professionals have much to be thankful for this Thanksgiving season. Here, Law360 reviews nine tax developments that professionals are grateful for in 2020.

  • 'Telescoping' Has Hazy Outlook Under Tax Overhaul, For Now

    Natalie Olivo

    The Internal Revenue Service's recent decision to limit "telescoping," where the agency moves corporate income adjustments for past years into current years, reflects how the 2017 tax overhaul's complexities conflict with preexisting administrative conveniences — at least for the foreseeable future.

Expert Analysis

  • Response Options For Danish Cum-Ex Interview Targets

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    As the Danish tax authority prepares for the first of a three-part U.K. trial involving cum-ex fraud, U.K. recipients of interview requests from the Danish prosecutorial agency should neither automatically accept, nor ignore the invitations, despite that agency's seeming lack of power to compel their attendance, says David Corker at Corker Binning.

  • Advancing The Democratic Tax Agenda In 2021

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    Even with a divided government starting next year, Democrats will have a major effect on tax policy, pursuing legislative compromises and regulatory changes in service of President-elect Joe Biden's tax plan, and potentially reversing many Trump administration initiatives, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.

  • M&A Poised For Growth In The Biden Era

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    The M&A market is well positioned for recovery and growth under a Biden administration and divided Congress, which will likely gain control over the coronavirus pandemic, pass a stimulus package, and provide greater transparency in antitrust enforcement, say attorneys at Debevoise.

  • Final BEAT Regs Still Contain Pitfalls For Taxpayers

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    Recently finalized U.S. Department of the Treasury regulations retain a taxpayer-friendly election allowing corporations to waive deductions to avoid the base erosion and anti-abuse tax, but neglect to include recourse for companies that waive more deductions than necessary, say attorneys at Ropes & Gray.

  • Post-Election Tax Policy Scenario 3: A Divided Government

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    Attorneys at Brownstein Hyatt consider whether Democrats and Republicans will find common ground on tax policies and legislation regarding COVID-19 relief, domestic research and manufacturing, pension and retirement savings, foreign taxation of U.S. companies, and infrastructure development if the upcoming election results in a divided government.

  • Post-Election Tax Policy Scenario 2: A Democratic Sweep

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    Russell Sullivan and Radha Mohan at Brownstein Hyatt consider former Vice President Joe Biden’s perspective that a better economy addresses income inequality, and the likelihood of passing specific tax measures in the event of a Democratic sweep, despite varying party perspectives.

  • Post-Election Tax Policy Scenario 1: A Republican Sweep

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    Attorneys at Brownstein Hyatt analyze tax policies implemented by the Trump administration, such as the Tax Cuts and Jobs Act, and consider what will be on the agenda if Republicans gain full control of both the legislative and executive branches in the election.

  • Defensive Strategies For High-Net-Worth Individual Tax Audits

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    When representing high-net-worth individuals in a tax audit, defensive strategies that cooperate with the examiner and respond to government requests should reflect the overarching goal of preserving client objections, privileges, limitations periods and any other rights in case there is future litigation, says Patrick McCann at Chamberlain Hrdlicka.

  • Canadian Tax Ruling Signals Cross-Border Structure Security

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    After the Tax Court of Canada's recent ruling in AgraCity v. The Queen that the company's arm's-length tax arrangements with a foreign subsidiary were legitimate, and a similar result in a different matter, Canadian taxpayers can have confidence that their cross-border related party transaction structures will be upheld, says Matt Billings at Duff & Phelps.

  • Preparing The Next Generation Of Female Trial Lawyers

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    To build the ranks of female trial attorneys, law firms must integrate them into every aspect of a case — from witness preparation to courtroom arguments — instead of relegating them to small roles, says Kalpana Srinivasan, co-managing partner at Susman Godfrey.

  • Mentorship Is Key To Fixing Drop-Off Of Women In Law

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    It falls to senior male attorneys to recognize the crisis female attorneys face as the pandemic amplifies an already unequal system and to offer their knowledge, experience and counsel to build a better future for women in law, says James Meadows at Culhane Meadows.

  • 5 Ways Firms Can Avoid Female Atty Exodus During Pandemic

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    The pandemic's disproportionate impact on women presents law firms with a unique opportunity to devise innovative policies that will address the increasing home life demands female lawyers face and help retain them long after COVID-19 is over, say Roberta Liebenberg at Fine Kaplan and Stephanie Scharf at Scharf Banks.

  • IRS Real Estate Push Should Wake Up Foreign Investors

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    Two recently announced Internal Revenue Service audit campaigns targeting nonresident alien investment in U.S. real estate should prompt foreign investors to prepare for greater scrutiny as the agency works to improve tax compliance around such transactions, say attorneys at Holland & Knight.